Privacy Policy

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Last updated on January 10, 2023

Ripple Care, Inc. and Rippl Care PC of Washington, Inc. (together “Rippl Care”) ( “Rippl Care”, “we”, “us”, or “our”) knows that you care about how your personal information is used and shared and we want you to be familiar with how we collect, use, and disclose that information. Rippl Care makes certain information (including telehealth information) available to you and/or facilitates your access to behavioral health services (“Rippl Care Services”) at ripplcare.com and the mobile application(s), if any, owned and operated by us (together, the “Website”). This Web Privacy Policy describes our practices for using, maintaining, sharing, and protecting your Personal Information (as that term is defined below). It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us. For the purposes of this Web Privacy Policy, “you” and “your” means you as the visitor of the Website.

SCOPE OF THIS WEB PRIVACY POLICY

This Web Privacy Policy does not apply to information collected from visitors who register and log-in (“Members”) to the password-protected and secure portions of our platform (the “Platform”). The Platform allows eligible Members to use the Rippl Care Services. The information collected and stored by Ripple Care or added by our Members into the Platform is considered Protected Health Information (“PHI”) and/or medical information and is governed by laws that apply to that information, for example the Health Insurance Portability and Accountability Act (HIPAA). How Rippl Care uses and discloses such PHI is in accordance with the applicable Notice of Privacy Practices. To understand how we use and disclose PHI, please review our Notice of Privacy Practices. In addition, this Web Privacy Policy does not apply to any website or service that is independent from Rippl Care to which we link to or that links to its own privacy policy and we recommend that you familiarize yourself with the privacy practices of those third parties. California residents should read the information below about the categories of personal information to be collected from them and the purposes for which the personal information will be used.

For purposes of this Web Privacy Policy, “Personal Information” includes any information that could be used to identify you and includes data such as your name, address, username, email address, telephone number, IP address or other digital identifying information. “Personal Health Information” or “PHI” has the meaning provided by the Health Insurance Portability and Accountability Act (HIPAA) and includes information related to your treatment or care such as health records, health histories, test results, medical bills, insurance information, etc.

This Privacy Web Policy is not a contract and does not create any contractual rights or obligations.

HOW RIPPL CARE COLLECTS PERSONAL INFORMATION

Rippl Care collects information about you from different sources and in various ways.

Information you provide directly. We may collect Personal Information that you provide to us directly including your name, phone number, date of birth, state, country, zip code, your health plan, email address or login identification when you begin registration to use the Platform, when you answer a questionnaire, or complete a web form seeking more information.
Information that is collected automatically. We may collect Personal Information automatically through your use of the Website. This information may include device information such as the model, operating systems, browser type, browser language, Internet Protocol (IP) address, country and time zone in which your device is located, the Website pages you viewed and how long you viewed them, and similar identifiers. We may also store and retrieve Personal Information using cookies, web beacons or other tracking technologies. Please see below for more information on tracking technologies.
Information received from third-parties. We may receive your Personal Information from other sources with your consent or as permitted by applicable law, such as from your insurance or healthcare provider, public databases, joint marketing partners, and other third parties.
Tracking Technologies. As described above, we may use various tracking technologies to collect information about you, one of which is called “cookies”. A cookie is an element of data that the Website can send to your browser, which may then be stored on your hard drive. Cookies may last for only a single session or may span multiple sessions. Finally, cookies are employed in other applications that require the storage of user data from one screen to the next. In accordance with applicable law, we may obtain your consent separately before collecting information by automated means using cookies or similar devices. Our Website may use Google Analytics, a vendor’s service that uses cookies, web beacons, web pixels and/or similar technology to collect and store anonymous information about you. You can learn more about Google Analytics’ privacy policy and ways to opt out from Google Analytics tracking by visiting Google Analytics’ website. Our Website may use Adobe’s analytics and on-site personalization services, which use cookies, web beacons, web pixels and/or similar technology to collect and store information about you or your device or browser. You can learn more about how Adobe may handle information collected through our use of its services, and your options for controlling this activity, by visiting Adobe’s website.

HOW RIPPL CARE USES PERSONAL INFORMATION

Rippl Care may have an arrangement with your insurance or healthcare provider and under that arrangement may be permitted to use and disclose your Personal Information as directed by them, consistent with applicable law. We may use your Personal Information for the following purposes:

To operate, maintain, supervise, administer, and enhance the Website, including monitoring and analyzing the effectiveness of content on the Website, aggregate site usage data, and other usage of the Website such as checking your eligibility and assisting you in completing the registration process.
To operate and manage our business (including by improving our own operations, securing our systems, conducting data analytics, detecting fraudulent or illegal activity to the event such use of Personal Information is permitted or required by your insurance or healthcare provider and applicable law.
To enhance and personalize your experience as you navigate our Website.
To provide customer support and respond to your questions as well as to communicate with you about the Rippl Care Services and those of other third parties.
To complete the activity you voluntarily and intentionally requested such as registering on the Platform.
Anonymize and aggregate information for analytics and reporting.
Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
Any other purpose with your consent or as may be authorized or required by applicable law.

HOW RIPPL CARE TRANSFERS OR DISCLOSES PERSONAL INFORMATION

We may share Personal Information with third parties in a variety of ways, including sharing your Personal Information:

With our employees, authorized contractors, and subcontractors who have a need to know such information in order to provide the Rippl Care Services.
With entities with whom we have contracted and who provide the Rippl Care Services including, without limitation, Rippl Care PC of Washington, Inc.
With the plan that administers the benefits available to you, without limitation, processing appeals and exceptions.
With vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security.
With professional advisors, such as auditors, law firms, and accounting firms.
With third parties at your direction. This includes your use of social media widgets on our Websites.
With any affiliates or subsidiaries within our corporate group.
To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
In connection with an asset sale, merger, bankruptcy, or other business transaction.
To enforce any applicable legal disclaimer, and to ensure the safety and security of the Website and/or our users.

We also may disclose de-identified information. Note that if you make any Personal Information publicly available on the Website, anyone may see and use such information.

HOW RIPPL CARE SECURES PERSONAL INFORMATION

We are committed to ensuring the data we collect, process and share is kept private and secure, and we have implemented reasonable and appropriate measures to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite these measures, no transmission or depository is guaranteed to be 100% secure and protecting the information is shared responsibility. You are responsible for using appropriate security measures to protect your Personal Information, including extending such protections to any account and login credentials associated with the Website or the Rippl Care Services.

HOW RIPPL CARE RETAINS YOUR PERSONAL INFORMATION

We will retain your Personal Information for only as long as necessary and as required for our business operations, to resolve disputes, to enforce agreements, for archival purposes, and/or to satisfy legal requirements. How long we keep the Personal Information is determined by criteria including the length of our relationship with you, whether we have a legal obligation to retain the Personal Information, or whether retention is advisable considering current legal positions such as any regulatory investigations. Once Rippl Care no longer has a need to retain your Personal Information, we follow our internal procedures and policies and, if possible, will either delete your

INTERNATIONAL USERS

The Website is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of our Website may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of Personal Information as the one in which you reside. However, we will handle your Personal Information in accordance with this Web Privacy Policy regardless of where your Personal Information is stored/accessed.

INDIVIDUAL RIGHTS

The following six rights are collectively referred to as the “Individual Rights.”

The right to access – You have the right to request copies of your Personal Information that Rippl Care possesses. We may charge you a small fee for this service;
The right to rectification – You have the right to request that Rippl Care correct any information you believe is inaccurate. You also have the right to request that Rippl Care complete information you believe is incomplete;
The right to erasure — You have the right to request that Rippl Care erase your Personal Information, under certain conditions;
The right to restrict processing – You have the right to request that Rippl Care stop processing of your Personal Information, under certain conditions;
The right to object to processing – You have the right to object to Rippl Care’s processing of your Personal Information, under certain conditions; and
The right to data portability – You have the right to request that Rippl Care transfer the Personal Information that we have collected to another organization, or directly to you, under certain circumstances.

If you would like to exercise any of your Individual Rights regarding Personal Information that you have previously provided to us, you may do so by contacting us in accordance with the “Contacting Us” section below. In your request, please make clear what Individual Right you are exercising. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information. We may be prevented from complying with a request to exercise an Individual Right. In such circumstances, we will respond to your request to exercise your Individual Right with a response stating that we cannot comply with such a request and, if legally allowed, why.

USE OF THE WEBSITE BY MINORS

Our Website is not intended for children under 16 years of age, and we do not knowingly collect or sell Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features. If we learn we have collected or received Personal Information from a minor under 16 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 16 years of age whom you believe might have provided us with their Personal Information, you may contact us using the below information to request that it be deleted.

CALIFORNIA RESIDENTS

If you are a resident of California the following information and rights are provided to you as required by the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice. Personal information under CCPA does not include:

Publicly available information from government
De-identified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
1. Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial
2. Financial Information covered by the Gramm-Leach-Bliley Act, and implementing regulations

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

Identifiers: Name, residential address, Internet Protocol (IP) address, email address, or other similar identifiers
Customer records information: Name, address, telephone number, medical information, health insurance information
Characteristics of protected classifications under California or federal law: Race, gender identity, age

We disclose your Personal Information for a business purpose to the following categories of third parties:

Service Providers: Cloud hosting, email delivery, medical record management, medical claims management, telehealth video platform, service desk management, platform usage analytics, business analytics, SMS delivery, log aggregation, geolocation

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you any of the following, as requested:

The categories of Personal Information we collected
The categories of sources for the Personal Information we collected
Our business or commercial purpose for collecting that Personal Information
The categories of third parties with whom we share that Personal Information
The specific pieces of Personal Information we collected
If we disclosed your Personal Information and identify the personal information categories that each category of recipient received

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Comply with a legal requirements
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
Debug products to identify and repair errors that impair existing intended uses of the products
Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing fees
Provide you a different level or quality of goods or services
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request

UPDATES TO THIS WEB PRIVACY POLICY

We may change this Web Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Web Privacy Policy was last revised. Any changes will become effective when we post the revised Web Privacy Policy on the Website. Your use of the Website following these changes means that you accept the revised Web Privacy Policy.

HOW TO CONTACT US

Should you have any questions about our privacy practices or this Web Privacy Policy, please email us at [email protected] or contact us at:

Privacy Officer
Rippl Care, Inc.
2825 Eastlake Avenue East
Suite 230
Seattle, WA 98012